Despite Government efforts, most online platforms in India refrain from resolving their dark patterns, finds LocalCircles

Sep 24, 2025, New Delhi: After multiple escalations on dark pattern issues by LocalCircles, earlier this year, the Ministry of Consumer Affairs and Public Distribution met with major online platforms to drive action against the dark patten gazette notification it had issued on November 30, 2023.

Dark patterns involve deceptive practices that manipulate users into making decisions they might not otherwise make. These patterns can lead to higher prices, hidden fees, subscription traps and a generally frustrating experience. In the "Guidelines for Prevention and Regulation of Dark Patterns" the CCPA defined the 13 dark patterns that will classify as unfair trade practices. Under the Consumer Protection Act, 2019, violations can attract penalties, including fines up to INR 20 lakh and imprisonment up to six months. However, there seems to be little let up in the use of dark patterns by apps and online platforms be it travel, hospitality, banking and insurance or eCommerce. On June 5, CCPA directed online platforms to undertake self-audit and get rid of dark patterns within 3 months. The three-month deadline is over but dark patterns seem to be continuing with little safeguards for consumers.

Based on consumer inputs, complaints and experiences, LocalCircles has compiled a comprehensive assessment of dark patterns on various online platforms after 18 months of consumer feedback and AI powered platform research. With inputs from over 250,000 consumers located across 392 districts of India across 290 different online platforms, LocalCircles has put together India’s most comprehensive repository on dark patterns as found in September.

Digital Lending, Edtech, Online Banking, eCommerce, OTT, App Taxis, Quick Commerce, Food Delivery platforms among those using 7 or more dark patterns

Based on over 250,000 inputs from consumers across 392 districts of India on LocalCircles, the study has found that 7 or more dark patterns are found on Digital Lending, Edtech, Online Banking, eCommerce, OTT, App Taxis, Inventory eCommerce, Food Delivery, Quick Commerce & Grocery, Apps and Software, Medicine and Health Services, Travel, Airlines, Movies/ Event Ticketing, Online Payments. Home and other Services, Online Gaming, Real Estate, Online Insurance, Foreign Currency, Broadband, Recruitment/ Professional Networking and Information Service. Next is the category with 4-6 dark patterns being reported include Train Ticketing, Mobile Telecom, Voice Assistants, Dinning Services, Governance Services, Home Health Services, Others, Electric Scooters, Online Financial Trading, Car Resale, Pathology & Diagnostics, Cryptocurrency, Matrimonial and Jewellery & Digital Gold. The third category of those with 1-3 dark patterns being reported include Car Rental, Hotels/ Homestays, Music Streaming and Mobile Devices.

Over 1 in 2 online platforms use Forced Action, Drip Pricing and Bait & Switch dark patterns

Based on analysis of over 290 online platforms in India and based on inputs, complaints and experiences of over 250,00 consumers across 392 districts, LocalCircles has found that some dark patterns are used more than others by various entities. Based on this analysis, among most used dark patterns Forced Action tops the list with 211 or 73% of platforms using it; 201 platforms or 69% have been found to use Drip Pricing; 155 platforms or 53% have been found to use Bait & Switch; 138 platforms or 47% have been found to use Interface Interference; 109 platforms or 38% have been found to use Nagging tactics; 106 platforms or 36% have been found to use Subscription Trap; 87 platforms or 30% have been found to be using Privacy Zuckering, a dark pattern not yet specifically identified by the CCPA but will still qualify as an unfair trade practice. In the next category, 56 platforms or 19% have been found to use Confirm Shaming; 47 platforms or 16% have been found to use Basket Sneaking; and 38 platforms or 13% have been found to use False Urgency method. In the third category, 23 platforms or 8% have been found to use SaaS Billing; 19 platforms or 7% have been found to use Disguised Ads to lure unsuspecting customers, while 1 platform or 0.34% has been found to use the Trick Question dark pattern.

The Forced Action dark pattern, many times involves forcing the user to take an action to move to the next transaction step. This may include, downloading an app or seeking personal data that is not required or mandatory to complete the transaction. This has been reported and validated across 74% platforms in India.

The Drip Pricing dark pattern, also referred to as Hidden Charges, involves not displaying prices upfront on a transparent basis and adding additional charges at the final step, many to the surprise of the consumer. Charges for delivery, convenience charges, processing charges, weather surcharges are typically not disclosed upfront and added at the last step, leading to final price of the product/service becoming as much as double of the base price. This has been reported and validated across 69% platforms in India.

The third dark pattern that is fairly common across Indian platforms is that of Bait & Switch where a product is typically displayed at a low price however the price changes upon user clicking it or adding it in the cart to a higher price. Another common example is showing a product at a low price but not displaying that the low price is applicable to just 1 unit. The user ends up adding multiple units in the cart with the additional units being billed at a higher price.

Overall, 22 months after the CCPA notified 13 dark patterns and asked online entities to desist from using them, there appears to be limited impact of the Government advisories and call to action with just 3% platforms in India being free of dark patterns. While some platforms have addressed a few of their dark patterns in the last 3 months, majority have ignored the CCPA advisories.

Over the course of the next 3 months, LocalCircles will release the sectoral level dark pattern data for all the major sectors covered in this report. The hope is that the regulators and platforms will take the time to understand these dark patterns not from their lens but the consumer lens and realise that addressing them is in the long term interest of their business as it will further consumer trust in their platform. If India is to become dark pattern free, not just CCPA but many other regulators and Government bodies including RBI, SEBI, TRAI, IRDAI CCI, FSSAI, DGCA, MIB, MEITY, Ministry of Railways, etc. will have to do their bit to ensure that their industry participants are working to make their platforms dark pattern free.